2. While processing personal data, Nave complies with all applicable data protection legislative acts, including but not limited to Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ('the Regulation').
3. According to the Regulation, Personal Data means any information relating to an identified or identifiable natural person (e. g. name, e-mail address, etc.). Location data, cookies and online identifiers such as IP addresses could also be considered Personal Data under the Regulation. Processing of Personal Data ("Processing") means any operation or set of operations which is performed with regard to the Personal Data such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
5. In relation to the use of the Website or the Product, Nave may process Personal Data of the following categories of Data Subjects:
a. Natural persons - Users with a free trial or a paid subscription plan who have signed up for the Product
b. Natural persons - Platform users (active or not) on dashboards synced with the Product
c. Natural persons representing and acting on behalf of an entity - User of the Product
d. Visitors of the Website
e. Natural persons, including such acting on behalf of an entity, who have provided feedback, registered a complaint, submitted a request to Us, asked Us a question or have addressed to or engaged in other type of correspondence with Us;
f. Natural persons, including such acting on behalf of an entity, who are mentioned in or are concerned by information contained in a query, complaint, requests or other correspondence submitted to Us by another person.
a. Data gathered from the platform
Setup of and login to the Product with the platform account
When You sign-up for the Product, You will be required to authenticate with Your platform login credentials and authorize Us to access some of Your platform data (name, the platform username, email address, Your platform boards and teams) which will allow Us to integrate and setup the Product with Your platform account, as permitted by your platform profile settings. At the moment of the authorization through the platform You provide Nave with the right to access the above mentioned data in Your platform account. The categories of data which Nave may be authorized to access are indicated in the authorization page. You are free to decide whether to authorize Nave's access to Your platform account. However, please bear in mind that in case You deny Us access, You may not be able to use the Product and take advantage of its features.
Insofar as the Product fully integrates with Your platform account, every time when You wish to access the Product through the Website You will need to authenticate using Your platform login credentials. For avoidance of any doubt, We do not, under any circumstances, store or process Your platform password. The latter is communicated directly to the platform. The platform then informs Us on the successful authentication by sending Us an authorization token which allows Us to log You in to the Product.
Use of the Product
The Product fully integrates with the platform: in order to generate cumulative flow diagrams, cycle time scatterplots, throughput histograms, etc. related to Your platform projects it accesses, syncs and displays information available within Your platform account as well as information related to the use of the platform features (boards, lists, cards, etc.). Depending on the content of Your platform account and on Your platform usage, the information which We may gather from the platform in order to provide You with the services within the Product, includes:
|Data related to Users||User id; URL to user avatar; email address; full name; username|
|Data related to other platform users within dashboards synced with the Product||User id; URL to user avatar; full name|
|Boards data||board id; name; organization id; short URL to the board; label names; preferences (board background image, board background color)|
|Organizations data||organization id; display name; memberships; URL to the logo; name|
|Lists data||list id; name; list position within the board; board id|
|Cards data||card id; name; board id; list id; labels id; members id; short URL to the card|
|Labels data||label id; name; color|
|Actions data||data related to changes to all typed of data above; date|
b. Data generated or gathered with relation to Your use of the Website or the Product
Data gathered by Nave with relation to Your sign-up to the Product
When You sign-up for the Product and accept Our Terms of Service, We will keep and store information proving for such acceptance (logs for date, time and source (IP address) of the acceptance).
Data Generated with Relation to the Use of the Product
Any information contained in vizualizations generated through the use of the Product is processed by Nave in real time. The vizualizations are made available to in real time through the Product website or through a generated URL for direct access to the Product graphs and visualizations.
Data gathered with relation to the use of the Website and mobile devices
Like many sites on the Internet We may use third-party service providers (such as Google Analytics, Hotjar, Drift, etc.) that automatically collect certain information when You visit the Website. This information may include Your IP address, Your browser type and language, access times, the content of any undeleted cookies that Your browser previously accepted from Us (see "Cookies" below) and referring/exit website address.
In addition, in case You are using a mobile device, We may also use third-party service providers that collect information through such device about Your device operating system, browser type, IP address, referring/exit website address, device identifiers, etc. Your IP address and/or country preference may thus be used in order to approximate Your location and provide You with a better user experience.
c. Financial information
Credit card details
In case You decide to sign-up for Our annual or monthly paid subscription plan upon expiration of the free trial period or upon subscription within the said trial period, You will be required to provide Your credit card details. These details are collected and processed by a third-party service provider via secure payment processing services. For avoidance of any doubt, We do not process or store credit card details ourselves.
Billing and payment information
We process certain payment and billing information related to You payments for Our annual or monthly paid Product subscription for which You have signed-up. For example, We will need to process the name of Your payment representative, billing address, amounts of payments due and of overpayments, date and time of payments, overdue payments and unpaid invoices, information contained in and related invoices and other financial and accounting documents, etc.
The billing information which We may process is directly related to Your activity and use of the platform and the Product. In order to assess and retrieve the amount of payments due and possibly overpayments for the use of the Product We may need to process information regarding the number of all active users and their activity throughout Your platform boards for the respective billing period.
d. Communications with You
We may use Your email address in order to send You Product-related announcements. These announcements include our on-boarding communications with respect to the sign-up to the Product, as well as Our email notifications for certain events related to Your sign-up and use of the Product.
We may also send You various communications with tips, tricks, ideas and good practices on how to optimize the use of the Product in case and to the extend You have not unsubscribed to such communications. With regard to such communications You are free to unsubscribe at any moment of Your subscription for the Product.
In an effort to update You with useful information regarding the newest products, services and special offers provided by Nave, We may occasionally send You emails or newsletter communications in case You have provided Us with Your explicit consent by subscribing to our marketing and newsletter communications list. In case You subscribe for receiving such communications from Us, We may process Your email address as well as logs for date, time and source (IP address) proving for the subscription.
If You do not wish to receive further such communications, You can, at any time, unsubscribe from receiving them by clicking at the "Unsubscribe" link at the bottom of the e-mail or newsletter.
In case You have expressly opted in, from time to time We may invite You to participate in Our surveys through which We aim to examine the opinion of Our users, customers and visitors of the Website. For the purposes of such surveys, We might process the following information related to You: email address, content of Your replies to the survey, as well as logs for date, time and source (IP address) of Your acceptance to participate to the survey and sending of Your reply.
Feedback, requests, complaints and correspondence
If You contact Us to provide feedback, submit request, register a complaint, or ask a question, including through the Website contact form, the Website online chat platform or via email, We will process the Personal Data and the other content which You provide in Your communication to Us so that We can effectively respond to Your request, complain or other communication. We will also process information on the status of Your feedback, request, complaint or other communication and the result from its processing by Us. Additionally, We may process Your Personal Data in case it is contained in feedbacks, requests, complaints, questions or other queries, submitted to Us by another person. In these instances, We will process Personal Data related to You solely to the extent needed for the purposes of replying to or taking action with regard to the respective feedback, request, complaint, question or query.
What are cookies?
Cookies are small text files that are placed on Your device (computer/ smartphone/ tablet) by websites that You visit. They are widely used in order to make websites work, to improve the user experience, as well as to provide information to the owners of the website about its traffic and usage. Cookies may be "session" or "persistent". "Session" cookies are stored on Your device until You leave the Website. Persistent cookies remain on Your device for a pre-defined period of time.
What types of cookies do We use?
|Type of cookies||Description||Storage period|
|Functional cookies||Functional cookies are cookies which are essential for the Website to work. For example, a "session" cookie which helps You navigate from one webpage to another through the Website is a functional cookie.||60000 sec|
|Non-functional cookies||Non-functional cookies are cookies which are not essential for the Website to work. For example, a cookie that helps the Website recognize You when You revisit it at a later point without a need for You to login again, is a non-functional cookie.||60000 sec|
|Third-party cookies||Third-party cookies are generally used for traffic analysis and personalized ads. You can refuse and/or delete them by rejecting them, when asked at the beginning of Your visit of the Website, by using the settings of Your web browser or by visiting the website of the respective provider and following the instructions thereon. For more information on third-party cookies which may be used throughout the Website and the Product, please, visit the following web pages: Google Analytics, Drift, HotJar, Lucky Orange.||NA|
Control over the cookies
As far as functional cookies are strictly necessary for the Website to work, You cannot refuse or limit their use. By using the Website, You confirm that You are informed on the use and storage of such cookies on Your device.
Non-functional cookies are not strictly necessary for the Website to work correctly. You can reject their use at the beginning of the visit of the Website. In addition, You can modify the settings of Your web browser or delete accepted cookies at any time. For further instructions, please visit the websites of the most popular browsers: Internet Explorer, Chrome, Firefox, Safari, Opera, iOS.
As for third-party cookies, You can refuse and/or delete them by rejecting them, when asked at the beginning of Your visit of the Website, by using the settings of Your web browser, as explained on the respective web browser's page quoted above, or by visiting the website of the respective provider and following the instructions thereon. For more information on third-party cookies which may be used throughout the Website and the Product, please, please visit the following web pages: GoogleAnalytics, Drift, HotJar, Lucky Orange.
a. Purposes necessary for the conclusion and performance of the contract concluded between You and Nave under the Terms of Service with regard to the use of the Product
b. Purposes necessary for protecting and exercising the legitimate interests of Nave and third parties
c. Purposes related to fulfilment of Nave's legal obligations
d. Purposes related to Your explicit consent provided to Nave
Processing of data for either of the below purposes may be conducted only in cases where You have provided Nave with Your separate explicit consent and solely within the scope and to the extent provided for by the respective consent. Accepting Our Terms of Service does not equal granting Us Your consent and would not justify or be sufficient for conducting data processing activities based on consent. When We process Personal Data on the basis of consent, We will clearly ask for Your separate and explicit such consent. The purposes for which We might do so, include:
8. Nave applies the principle of storing data in minimal volume and for a period not longer than the strictly necessary to the purposes for which data were collected, ensuring that data are stored securely and in compliance with the applicable legislation.
We store the enlisted types of data for the following period:
|Type of data||Storage period|
|Data contained in documents related to payments, invoices, accounting documents||10 (ten) years, counting from the beginning of the year following the one during which the payment is due|
|Data created with regard to Your subscription (free trial or paid) for and use of the Product, except for data related to payments, invoices, accounting and other financial activities||For the entire period Your subscription is active and maintained by Us and up to 3 (three) months following the expiration of the Product's trial period or the termination of Your paid subscription|
|Logs||For date and time, and for source (IP address) of actions undertaken by You with regard to Our contractual relations (subscription, payments, acceptance of Terms of Service, etc.)||For the entire period Your subscription is active and maintained by Us and up to 3 (three) months following the expiration of the Product's trial period or the termination of Your paid subscription|
|For date and time, and for source (IP address) of actions with regard to providing/ withdrawing consent||Until the consent is withdrawn and for a reasonable period of time following the "Unsubscribe" request, necessary to the processing of the request.|
|For login/ authentication to the Product||3 (three) months counting from the last login|
|Server and system||3 (three) months|
|Correspondence, incl. but not limited to feedback, requests, complaints and claims||In case the correspondence is carried out with a subscriber of the Product – for the entire period the respective subscription is active and is maintained by Us and up to 5 (five) years following the termination of the subscription.
For correspondence carried out with other persons – for a period of 5 (five) years following the last action undertaken as a result of the respective correspondence.
|Data processed on the grounds of Your explicit consent provided to Nave||Until the consent is withdrawn and for a reasonable period of time following the "Unsubscribe" request, necessary to the processing of the request.|
In case of a legal dispute or proceedings requiring data retention and/or in case of a request of a competent state authority, data may be stored for longer periods than the ones specified above, until the final settlement of the dispute or proceedings before all instances. Data storage periods may also be changed according to the requirements of applicable legislation.
a. Data processors
Nave may engage subcontractors and service providers to perform task on behalf of Nave – data processors, such as dedicated data centers for reliable and secure colocation of servers and network equipment, providers of accounting services, developers, providers of marketing assistance, etc. When engaging such processors, We require that they access and process Personal Data solely on behalf of Nave and to the extent strictly necessary to the performance of their tasks assigned by Nave. All such subcontractors and service providers are contractually obliged to strictly comply with Nave's documented instructions and are prohibited from using the Personal Data for other purposes.
b. Other data controllers
In certain cases, Nave may share Your Personal Data with its business partners and contractors – other data controllers, such as third-party financial transaction facilitators, (Stripe, PayPal), web traffic analysis service providers (Google Analytics, Hotjar, Drift), etc. When We work with other data controllers, We adequately settle the rights and obligations of both parties with regard to the processing of personal data (incl. the prohibition of using Personal Data for purposes other than those related to the fulfillment of the respective party's tasks), by concluding specific Data Processing Agreements with them.
c. Other instances
We may also disclose Your Personal Data to third parties:
|Right of access||You are entitled to receive confirmation whether Your Personal Data is being processed, to receive access to it, as well as to obtain information about the processing and Your rights.|
|Right of rectification||
You are entitled to have Your Personal Data rectified in case it is incomplete or inaccurate. Your data may be rectified by Us upon a request from Your side. Please note that We cannot rectify Personal Data which You have authorized Us to gather from the platform. Such data may be rectified solely throught the platform. For more information on how this may be done, please refer to the platform Terms of service and privacy documents.
In addition, You can modify certain of Your Personal Data (credit card number, billing name and address) collected and processed by third-party service providers for secure payment services by re-entering it in the respective form.
|Right of erasure||You have the right to request for Your Personal Data to be erased unless there is a legal ground and/or legal obligation for their processing. When exercising this right, please keep in mind that certain data is required for the correct functioning of the Website/ the Product.|
|Right of restriction of the processing||You have the right to make a request for restricting the processing of Your Personal Data in case there are grounds for this provided by the applicable legislation.|
|Right to notify third parties||Where applicable, You have the right to request from Nave to notify third parties on the rectification, erasure or restriction of the processing of Your Personal Data in case Nave has provided Your data to such third parties.|
|Right of data portability||You have the right to receive the Personal Data related to You which You have provided to Nave, in a structured, commonly used, machine-readable format, and to provide these data to another data controller. Where technically feasible, You can request Nave to directly provide Your Personal Data to another data controller.|
|Right not to be subject to a decision based solely on automated processing||You have the right not to be subject to a decision based solely on automated processing, including profiling which produces legal effects concerning or significantly affecting You unless there are grounds provided for by the applicable data protection legislation, as well as appropriate safeguards to protect Your rights, freedoms and legitimate interests.|
|Right to withdraw Your consent||In case You have provided Us with Your prior consent for processing of Your Personal Data, You have the right to withdraw this consent at any time. Such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal. For instance, You can unsubscribe from receiving marketing communications and newsletters by clicking at the "Unsubscribe" link at the bottom of the e-mail or newsletter.|
|Right to object to the processing||You have the right, at any time and on grounds related to the specific case, to object to the processing of Your Personal Data processed on the basis of legitimate interest. In the event of such an objection We will examine Your request and, if justified, We will comply with it. If We believe there are sufficient legal grounds for the processing or the processing is necessary for establishing, exercising or defending legal claims, We will inform You accordingly.|
Exercise Your rights
11. You can exercise the above rights at any time by sending Us a message via the contact form available in the "Contact" section of the Website or an email at email@example.com.
Right to lodge a complaint with a supervisory authority
12. You have the right to lodge a complaint with a supervisory authority if You consider that the processing of Your Personal Data infringes on the applicable data protection legislation. The supervisory authority in the Republic of Bulgaria is the Commission of Personal Data Protection, with address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592.
13. Nave Ltd. is a company duly registered and existing under the laws of the Republic of Bulgaria, with company number 202979859 and seat and registered address in Bulgaria, 1336 Sofia, Lyulin Residential District, building 384, entry A, floor 7, ap. 20.
14. In case You have any questions or queries with regard to the processing of Your personal data by Nave, please contact Us at +32 (0) 470 998915 or email Us at: firstname.lastname@example.org and We will be happy to assist or provide You with further information.
Last update: 30.11.2018